Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Valuation of imported goods - aircraft engine - vehicle expressly imported for a limited period and for ‘stop gap’ fitment during the overhaul of the regular engines by the provider of the imported replacement - The impugned order has adopted a base value to which additions have been made and, in the process, utilized a notional price in the agreement that is neither price paid nor price payable which is a necessary qualification for ‘transaction value’ of ‘imported goods’, ‘identical goods’ or ‘similar goods’ in rule 3, 4 and 5 - Likewise rule 7 and 8 of the said Rules specify the circumstances that validate appraisal. - AT
Valuation of imported goods - aircraft engine - vehicle expressly imported for a limited period and for ‘stop gap’ fitment during the overhaul of the regular engines by the provider of the imported replacement - The impugned order has adopted a base value to which additions have been made and, in the process, utilized a notional price in the agreement that is neither price paid nor price payable which is a necessary qualification for ‘transaction value’ of ‘imported goods’, ‘identical goods’ or ‘similar goods’ in rule 3, 4 and 5 - Likewise rule 7 and 8 of the said Rules specify the circumstances that validate appraisal. - AT
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